CCGGA Opposes Air Resources Board Freight Facility Survey for 2017

The California Air Resources Board (CARB) held a public workshop yesterday to discuss “Data Collection and Freight Hub Survey” as part of CARB’s Sustainable Freight Strategy. This issue from early on has been an extreme concern of the California Cotton Ginners and Growers Associations (CCGGA) as the loose term of freight facility and warehouse/distribution center could include cotton ginning operations among other agricultural post-harvest facilities. This is critical as CARB eyes future rulemaking that, while not explicit stating it, could lead to the potential of a facility based diminishing emissions cap. Director of Regulatory Affairs Jodi Raley was among the very few participants in yesterday’s workshop and the only agricultural organization to comment on the matter. CCGGA’s comments included opposition to the survey presented as we believe the questions asked are not needed, contain sensitive information or data can be attained through CARB’s current resources. Additionally, CCGGA commented on the concern our Association has with CARB’s aggressive survey approach as it was just a month ago that the agriculture industry received the Large-Spark Ignition (aka Forklift) and Transportation Refrigeration Unit survey. CARB claims that they are still developing the definition and criteria of facilities that would be included on this survey, however they are stating they are eyeing a potential 55,000 facilities that they have identified thus far based off of tax assessor document along with aerial imaging identifying loading docks/bays. We will be following up with detailed comments and continued pressure to identify who will be targeted for this survey.